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SEC Company Response from TEVA PHARMACEUTICAL INDUSTRIES LTD (TEVA, TEVJF) (CIK 0000818686) (TEVA) — Apr 16, 2018

TEVA PHARMACEUTICAL INDUSTRIES LTD (TEVA, TEVJF) (CIK 0000818686)
Date: April 16, 2018 · CIK: 0000818686 · Accession: 0001193125-18-118596

AI Filing Summary & Sentiment

File numbers found in text: 333-224102

Date
April 16, 2018
Author
Teva Pharmaceutical Industries Limited
Form
CORRESP
Company
TEVA PHARMACEUTICAL INDUSTRIES LTD (TEVA, TEVJF) (CIK 0000818686)

Letter

Acceleration Letter

Teva Pharmaceutical Industries Limited

5 Basel Street

P.O. Box

Petach Tikva, 4951033 Israel

April 16, 2018

Via EDGAR Submission

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549-3561

Re: Teva Pharmaceutical Industries Limited

Registration Statement on Form S-4 (File No. 333-224102)

Ladies and Gentlemen:

Pursuant to Rule 461 of the Securities Act of 1933, as amended (the “Act”), Teva Pharmaceutical Industries Limited (the “Company”), Teva Pharmaceutical Finance Netherlands II B.V. and Teva Pharmaceutical Finance Netherlands III B.V. (collectively, the “Registrants”) hereby request acceleration of the effective date of its Registration Statement on Form S-4 (SEC File No. 333-224102) (the “Registration Statement”), to 8:00 a.m., Eastern Time, on Thursday, April 19, 2018, or as soon thereafter as possible. The Registrants hereby acknowledge their responsibilities under the Act and the Securities Exchange Act of 1934, as amended, as they relate to the proposed exchange offer of the securities specified in the Registration Statement.

U.S. Securities and Exchange Commission

April 16, 2018

Page

Please contact Ross M. Leff of Kirkland & Ellis LLP, special counsel to the Company, at (212) 446-4947, as soon as the Registration Statement has been declared effective, or if you have any other questions or concerns regarding this matter.

Sincerely,
Teva Pharmaceutical Industries Limited

Show Raw Text
CORRESP
1
filename1.htm

Acceleration Letter

 Teva Pharmaceutical Industries Limited

5 Basel Street

 P.O. Box
3190

 Petach Tikva, 4951033 Israel

April 16, 2018

 Via EDGAR Submission

Securities and Exchange Commission

 Division of Corporation
Finance

 100 F Street, N.E.

 Washington, D.C. 20549-3561

Re:
Teva Pharmaceutical Industries Limited

 Registration Statement on Form S-4 (File No. 333-224102)

 Ladies and Gentlemen:

Pursuant to Rule 461 of the Securities Act of 1933, as amended (the “Act”), Teva Pharmaceutical Industries Limited (the
“Company”), Teva Pharmaceutical Finance Netherlands II B.V. and Teva Pharmaceutical Finance Netherlands III B.V. (collectively, the “Registrants”) hereby request acceleration of the effective date of its
Registration Statement on Form S-4 (SEC File No. 333-224102) (the “Registration Statement”), to 8:00 a.m., Eastern Time, on Thursday, April 19,
2018, or as soon thereafter as possible. The Registrants hereby acknowledge their responsibilities under the Act and the Securities Exchange Act of 1934, as amended, as they relate to the proposed exchange offer of the securities specified in the
Registration Statement.

 U.S. Securities and Exchange Commission

April 16, 2018

  Page
 2

 Please contact Ross M. Leff of Kirkland & Ellis LLP, special counsel to the Company,
at (212) 446-4947, as soon as the Registration Statement has been declared effective, or if you have any other questions or concerns regarding this matter.

Sincerely,

Teva Pharmaceutical Industries Limited

By:

/s/ Deborah Griffin

Name:

Deborah Griffin

Title:

Senior Vice President and Chief Accounting Officer

Teva Pharmaceutical Finance Netherlands II B.V.

By:

 Teva Pharmaceuticals Europe B.V.,

 its Managing
Director

By:

/s/ David Vrhovec

Name:

David Vrhovec

Title:

Managing Director

By:

/s/ John Nason

Name:

John Nason

Title:

Managing Director

Teva Pharmaceutical Finance Netherlands III B.V.

By:

 Teva Pharmaceuticals Europe B.V.,

 its Managing
Director

By:

/s/ David Vrhovec

Name:

David Vrhovec

Title:

Managing Director

By:

/s/ John Nason

Name:

John Nason

Title:

Managing Director

cc:
Ross M. Leff

 Kirkland & Ellis LLP